RIS 00-006: Consolidated Line Item Improvement Process for Adopting Standard Technical Specifications Changes for Power Reactors

March 20, 2000


All holders of operating licenses for nuclear power reactors, except those who have permanently ceased operations and have certified that fuel has been permanently removed from the reactor vessel.

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The U.S. Nuclear Regulatory Commission (NRC) is issuing this regulatory issue summary (RIS) to inform the addressees of the opportunity to participate as applicants in the consolidated line item improvement process (CLIIP) for Technical Specifications (TS) amendments. The CLIIP facilitates licensees' adopting of NRC-accepted changes to the Standard Technical Specifications (STS) for their specific plant TS. This process is intended to streamline the license amendment review process involving NRC-accepted STS changes in order to increase NRC efficiency and reduce unnecessary regulatory burden. The NRC role in maintaining plant safety is achieved by the technical review of proposed changes to the STS as well as plant-specific applications to adopt NRC-accepted changes to the STS. In addition, the CLIIP is intended to increase public confidence by making NRC's work process more visible to its stakeholders.

The CLIIP improves the efficiency of the NRC licensing processes by reviewing and documenting STS change requests in a manner that supports subsequent license amendment applications. By soliciting comments from NRC stakeholders, the CLIIP enhances the visibility of the staff's review and revision processes for the STS as well as subsequent license amendment applications. Following the staff's resolution of public comments on a proposed change to the STS, the licensees may submit a license amendment application to adopt the NRC-accepted change by citing the relevant information which would have been made available. Each amendment application made as part of the CLIIP will be processed and noticed in accordance with applicable rules and NRC procedures.

This RIS does not create any new or changed NRC requirements or staff positions, and it requires no specific action or written response. Participation in the CLIIP is purely voluntary.

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The STS for the five vendor designs include Babcock & Wilcox (NUREG-1430), Westinghouse (NUREG-1431), Combustion Engineering (NUREG-1432), General Electric Boiling Water Reactor/4 (BWR/4) (NUREG-1433), and General Electric BWR/6 (NUREG-1434). The review of a proposed generic change to the STS is a multi-staged process designed to ensure that each STS remains internally consistent, maintains coherence among the various vendors' STS, and incorporates the knowledge and operating experience of the industry and the NRC.

Changes to the STS NUREGs, which are potentially applicable to multiple plants, are proposed to the NRC by the Nuclear Energy Institute (NEI) sponsored Technical Specification Task Force (TSTF) through publicly available submittals. The TSTF includes representatives from the four U.S. commercial nuclear power plant owners groups and NEI. The NRC staff reviews the changes to the STS proposed by the TSTF (referred to as TSTF changes) and will accept, modify, or reject them. Once TSTF changes are accepted, they are considered to be part of the STS. Individual licensees may propose to adopt the TSTF changes during a conversion to the STS or as a separate license amendment application.

The objective of the CLIIP is to improve the efficiencies in the processes for NRC review and licensees' preparation of license amendment applications for NRC-accepted TSTF changes. This is primarily accomplished through multiple licensees being able to use the approved safety evaluation prepared for the TSTF change in connection with amendment applications for specific plants. In an effort to make the NRC work processes more visible, the NRC staff will solicit stakeholder comments on the associated change to the STS, the staff's safety evaluation (SE), and the proposed no significant hazards consideration determination (PNSHCD) before finalizing its acceptance of a TSTF change. Following NRC acceptance of a TSTF change, licensees, as well as the NRC staff, will be able to use the relevant documentation from the NRC-accepted TSTF change in the preparation and processing of license amendment applications. Some of the features of CLIIP incorporate lessons learned from the staff's experiences during the development of the STS and related NRC Policy Statements on TS improvements (e.g., issuing generic letters to announce the availability of "line item improvements" to TS).

The CLIIP would allow efficient adoption of the TSTF changes by licensees that have converted to the STS, as well as by licensees that have not converted to the STS but have determined that the TSTF changes are applicable to their facilities. This process would streamline the documentation process for both the NRC and the licensees. Furthermore, stakeholder involvement would be fostered from the beginning of this process.

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The purpose of the CLIIP is to streamline the license amendment review process involving TSTF changes applicable to multiple plants. By using a standardized process such as the CLIIP, the burden on an individual licensee would be reduced by saving resources in preparing license amendment applications and, at the same time, the NRC staff review process would become more efficient. The attached flow chart details the process flow for the CLIIP. There are three required participants in the process flow map: the NEI TSTF, the NRC staff, and the licensees. In addition, all NRC stakeholders are provided an opportunity to comment on a proposed TSTF change before NRC acceptance of the change, as well as to participate in the licensing process for each license amendment application. The major aspects of this process are summarized as follows:

  1. The CLIIP will improve the efficient adoption of NRC-accepted TSTF changes by having the staff prepare and publish a safety evaluation (SE). A TSTF change request from the NEI TSTF will include a technical justification and a PNSHCD as part of the proposal. The TSTF change process supports subsequent license amendment applications.

  2. Following its preliminary review, the NRC staff will use a Federal Register notice (FRN) and the NRC website to inform and solicit comments from NRC stakeholders regarding the proposed TSTF changes that will be incorporated into the CLIIP. The stakeholders will be provided with a description of the TSTF change, the staff's preliminary safety evaluation, and a PNSHCD. After the NRC staff resolves the public comments, another FRN and the NRC website will be used to notify NRC stakeholders if the TSTF change has been accepted by the NRC staff and, if accepted, that the TSTF change is available for adoption in proposed plant-specific license amendment applications.

  3. The licensees desiring to adopt a specific TSTF change using the CLIIP will need to verify that the proposed change is applicable to their facilities. The NRC announcement and the staff's SE will specify any plant-specific verification or other information required in licensees' applications. The licensees may apply for license amendments by citing the applicability of the PNSHCD and the SE for the accepted TSTF change and addressing any plant-specific information needed to support the staff's review. In order to obtain the maximum efficiency gains from the CLIIP, the NRC will recommend that the licensees submit their applications within a specified time following the FRN announcing that the TSTF change has been accepted.

  4. Each amendment application made as part of the CLIIP will be processed and noticed in accordance with applicable rules and NRC procedures. The NRC efficiency gains are achieved by reducing the plant-specific reviews for those changes that are common to multiple licensees.

By using this process, the CLIIP would allow licensees that have converted to the STS to efficiently adopt the accepted TSTF changes subsequent to the conversion. It would also facilitate efficient adoption of accepted TSTF changes as STS evolve for nonconverted plants. Finally, with the licensee's adoption of the uniform description of the proposed change, the PNSHCD, and the SE for a TSTF change request, the CLIIP would provide more disciplined and consistent adoption of the STS by way of a streamlined amendment process.

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This RIS does not request any action or written response; therefore, the staff did not perform a backfit analysis.

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A notice of opportunity for public comment on this RIS was not published in the Federal Register because the CLIIP is simply a more effective and efficient application of existing regulations and NRC work processes. The process was developed with opportunities for input from stakeholders during public meetings. The CLIIP adds opportunities for the public to participate in the licensing process.

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This RIS does not request any information collection.

If there is any question about this RIS, please contact the persons listed below.

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David B. Matthews, Director
Division of Regulatory Improvement Programs
Office of Nuclear Reactor Regulation

Technical contacts: Tilda Y. Liu, NRR
E-mail: Tilda.Liu@nrc.gov
  William D. Reckley, NRR
E-mail: William.Reckley@nrc.gov
  1. Consolidated Line Item Improvement Process (CLIIP) Flow Chart
  2. List of Recently Issued NRC Regulatory Issue Summaries

(ADAMS Accession Number ML003693442)

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